Clarifications to Reg Needed to Make NOP Work for Personal Care Products, AHPA Says

SILVER SPRING, MD May 14, 2009 – The American Herbal Products Association (AHPA) suggests in comments submitted May 7 that a National Organic Standards Board (NOSB) committee consider adding several key points to a proposed recommendation that the National Organic Program (NOP) be amended to explicitly include cosmetics.

The proposed recommendation by the Board’s Certification, Accreditation and Compliance Committee (CACC) was a topic of discussion during an NOSB public meeting held May 4-6 in Washington, D.C. AHPA President Michael McGuffin presented the association’s comments before the NOSB on May 4.

“In looking for consensus among AHPA members on the topic of including cosmetics in the scope of the NOP, it is clear that additional effort must be given to making the NOP work for all agricultural products, including cosmetics and personal care products,” said McGuffin. “AHPA’s suggestions represent a starting point for this effort.”

Among other suggestions, AHPA proposes the addition of a section to the NOP to identify “synthetics allowed in or on processed cosmetic products labeled as ‘organic’ or ‘made with organic (specific ingredients or ingredient groups’).”

AHPA also suggests the regulation’s definition of an “agricultural product” be revised to add a descriptive definition at the end of the current definition to clarify that the term is used “without regard to the end use of the product, so that an agricultural product may be in the form of a food, a dietary supplement, a nonprescription drug, a cosmetic or any other product that is processed from agricultural crops or from livestock.”

“One point of agreement among AHPA’s members is on advocating for a finished product certification system that will maximize the marketplace for organically grown crops,” McGuffin said. “The vision implied by this point of advocacy is one of many more acres of organically grown herbal crops.”

According to the draft discussion document, CACC will incorporate feedback received during the public meeting, and present a recommendation on the topic to NOSB in the Fall.

AHPA’s comments are available here:

The CACC draft discussion document is also online:


The American Herbal Products Association (AHPA) is the only national trade association devoted to herbal issues. Representing the core of the botanical trade—comprised of the finest growers, processors, manufacturers and marketers of herbal products—our mission is to promote the responsible commerce of herbal products. AHPA committees generate self-regulations to ensure the highest level of quality with respect to the way herbal products are manufactured, labeled, and sold. Website:

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